The Pike and San Isabel National Forests, Cimarron and Comanche National Grasslands
2840 Kachina Drive
Pueblo, CO 81008
Pike & San Isabel National Forests, Public Motor Vehicle Use
Draft Environmental Impact Statement (DEIS) Comments
Dear Supervisor Trujillo:
Please accept this brief Executive Summary of comments regarding the Pike & San Isabel National Forests (PSINF) Public Motor Vehicle Use; Draft Environmental Impact Statement (DEIS) on behalf of the Trails Preservation Alliance (TPA), the Colorado Off-Highway Vehicle Coalition (COHVCO) and our affiliated clubs and groups. Recall that in 2011 both the TPA and COHVCO joined the PSINF as intervening partners to help defend against the lawsuit that began the MVUM Analysis Project. The TPA and COHVCO have both invested substantial financial resources since 2011 to defend the PSINF and the United States Forest Service (USFS). Our affiliated groups include enthusiast clubs from the communities within the area encompassed by the PSINF. The TPA, COHVCO and our affiliates are referred to collectively in this correspondence as “The Organizations.”
- The Organizations would like to thank the employees and staff of the Pike & San Isabel National Forests, the United States Forest Service and the Contractor’s staff for their work and completion of the Pike & San Isabel National Forest, Public Motor Vehicle Use DEIS. The Organizations recognize and appreciate the substantial amount of work and effort that it has taken to accomplish this major milestone in the project.
- During the review of the DEIS documents, the Organizations are compelled to note the following concerns with the documents provided for public review
- The shear volume of pages and sheets that make up the complete set of data and information presented in the DEIS is in of itself extremely large and overwhelming for a citizen to be expected to review and provide meaningful input and prepare comments on. With 5 separate alternatives and 5 map panels per alternative, a complete set of maps is 25 sheets. The DEIS document itself is 378 pages, again an intimating volume of information for a citizen to review, comprehend and understand. Appendix C contains 70 pages of spreadsheets. Likewise should a citizen prefer to print the entire DEIS (not including the Specialist Reports) in a format suitable for reading, the printing cost alone is likely to exceed $250.00 per copy (color printing is required to discern data and information in figures and maps).
- The spreadsheets contained in Appendix C are formatted on pages with extremely small print. When printed on 11”x14” paper, the spreadsheets are still too small to be read and understood in a meaningful a manner.
- The map sheets issued for Alternative C depict and show “new routes” on the maps that to the casual observer may incorrectly deduce that Alternative C includes those new routes, which is not the case.
- The map sheets for Alternative D are missing entire route line segments. For example, most of the 717-trail system on Sheet 1 of 5 is missing the actual route lines for the 717 trails. The labels (i.e. “717”) are present on the maps but the actual route lines are missing.
- The Organizations must question why the Purpose and Need for this project, as stated in the DEIS, was noticeably and substantially changed in the period of time between the publication of the Notice of Intent/Scoping Phase and publication of the DEIS. This change in Purpose and Need must be explained in detail to the public in the Final EIS.
- The project Specialist Reports, such as the Transportation, Soils and Recreation Reports, need to be revised and updated to reflect Alternative C as the Proposed Action/Alternative. Currently the reports incorrectly identify Alternative B as the “proposed action”.
- The DEIS does not provide adequate or necessary information on proposed dates for Seasonal Closures which hampers the public’s ability to prepare and provide substantive and meaningful comments. On October 29, 2019 an email was sent out by the USFS with a link to a spreadsheet that listed proposed “seasonal closure dates”. This email was sent out just days prior to the deadline for DEIS comment submission. The spreadsheet contained 3,838 individual lines of information that the public was expected to review and provide comments on. This was an unreasonable and excessive request of the public on behalf of the USFS and PSI Project Team.
- At this time, The Organizations generally believe that the proposed Alternative C satisfies the terms of the Settlement Agreement. The Organizations provisionally support Alternative C with modifications (as outlined below) and as long as there are no additional closures, decommissioning, restrictions (e.g., seasonal closures, restrictions on motorized use, etc.) or conversion of the routes (as proposed in Alternative C) to Admin Use Only, Special Use Permit, or Maintenance Level 1. For the Organizations to support Alternative C the following modifications are essential and necessary to meet the stated Purpose and Need of this project. A brief summary of what we consider the essential additions and modifications to the Alternative C are provided below:
Summary of Specific Additions and or Modifications to Alternative C (Proposed Alternative) Leadville Ranger District “Keep as is” all segments of NFSRs 398, 398.B and 399 and do not convert to special use permit only. Add all New Parking Areas as proposed in Alternative D to improve management of vehicle parking, improve safety and reduce resource damages adjacent to roads and trails caused by unmanaged and unregulated vehicle parking. Pikes Peak Ranger District Add and designate new routes proposed in Alternative D; PA 7, 10, 13, 14, 16, 17, 28 and others in the Gold Camp Road area as Open to Motorcycles.* Add and designate new routes proposed in Alternative D; PA 42, 43, 44, 54 and others in the Rainbow Falls area as Open to Motorcycles. (Re: South Rampart Travel Management Plan).* Add the connection across SH 67 near Rainbow Falls, PA 25 along with New Trails 1 & 2 that connects NFSRs 340.B & 343.B with NFSR 357. Keep NFSR 346 “as is” (i.e. Open to All Vehicles) with no seasonal closures and add PA 18 (route Open to All Vehicles) to connect NFSRs 346 and 300.F to help disperse use. Immediately re-open NFSR 322A and re-establish the connection between NFSR’s 320 and 322 and convert to a Trail Open to All Vehicles or Open to Motorcycles Only. This action will re-establishes historic connectivity and provide historic and additional looped route opportunities. Add all New Parking Areas as proposed in Alternative D to improve management of vehicle parking, improve safety and reduce resource damages adjacent to roads and trails caused by unmanaged and unregulated vehicle parking. Eliminate the existing and proposed Seasonal Closure on Rampart Range Road, NFSR 300. Eliminate the existing and proposed seasonal closure on NFSR 376.A. Add New routes PA 26, 32, 115, 63, 110, 111, 25, 26, 41, 46, 48, 51, 53.
New Trails 1 & 2
Add new “Areas Open to Motor Vehicles” especially those previously planned in the South Rampart Travel Management Plan (i.e., PA 32 & PA 33) Salida Ranger District Add new routes PA 2 & PA 6 between NFSRs 204 & 210 to provide loops and connections. Keep NFSR 349 (Grassy Gulch) “as is” for it’s entire length and eliminate the proposed decommissioning of the upper segment. Add all New Parking Areas as proposed in Alternative D to improve management of vehicle parking, improve safety and reduce resource damages adjacent to roads and trails caused by unmanaged and unregulated vehicle parking. Keep NFSR 298.A (Williams Pass) as Open to Public Motor Vehicle use and eliminate all proposals to convert to a non-motorized trail. Trail conversion to non-motorized use will eliminate connectivity with the west side of the Williams Pass route in the Gunnison Ranger District. Reopen access for motorcycles to NFSR 225.F. Remove existing or proposed seasonal closures on NFSRs 185.D, 101,108, 212 and NFST 1336. San Carlos Ranger District Add new Trails PA 1 & PA 8.
Add new “Areas Open to Motor Vehicles” (i.e., PA 9 & PA 15).
South Park Ranger District Add new Routes PA 5, 11, 12 and 116 Add new Road 2 Re-establish public access and connectivity to Wildcat Canyon. Convert roads/routes on the western banks of the South Platte River to Trails Open to All Vehicles (e.g. NFSR 221, 220A, 220B, 540, etc.) Eliminate the existing and proposed Seasonal Closure on China Wall, NFSRs 212 and 212.A. Keep NFSR 603 “as is” and open to public access. Add new “Areas Open to Motor Vehicles” (i.e., PA 4 & PA 29) South Platte Ranger District Add new Road 3 Eliminate the existing and proposed Seasonal Slaughterhouse Gulch and Crow Creek, NFSRs 105 and 101. Add new Trails 3 and 4 Re-establish public access and connectivity to Wildcat Canyon. Convert roads/routes on the western banks of the South Platte River to Trails Open to All Vehicles (e.g. NFSR 221, 220A, 220B, 540, etc.) NFSR 126 (aka Twin Cone), reopen and reestablish access to the upper section of the route, covert to a trail open to all vehicles (i.e. MP 5.13 to 7.37)
*The TPA and its affiliates will support the procurement of CPW OHV grants for the construction and maintenance of these trails and is willing to discuss future volunteer support and possible trail adoption.
- The Organizations do not and cannot support the proposed Alternatives B and E as they each seek to eliminate an excessive number of viable routes and neither alternative fulfills the Purpose and Need Statement for this project. Neither Alternative B nor E meets the needs for sustainable and proper forest, timber and fuels management along with motorized travel management and multiple-use recreation. Elimination of routes at the magnitude proposed by these two alternatives will not protect the environment, will not protect natural or cultural resources, and does not fulfill the originally stated Purpose and Need of this project “…to improve the management of motor vehicle use…” on the PSINF. Alternatives B and E do not achieve an improvement in management and do not provide even a minimal, basic or rudimentary access to the PSINF for management, timber or fuels management, access to private property, access to public and private utility infrastructures, access in times of emergency (i.e. search and rescue operations) and certainly not for the multiple-use recreational needs of a Forest(s) in such close proximity to major population centers like Colorado Springs, Pueblo and Denver. The Organizations must also emphatically point out the Alternatives B and E do not have a basis for their proposed changes and reductions to the roads and motorized trails network founded on scientific or other important and relevant data. The Organizations can not support Alternative A as it relies upon old, out dated information and does not adequately reflect current conditions and lacks planning for future needs and uses.
- As stated in Notice of Intent (NOI) for this project, the original Purpose and Need for this Action is “…to improve management of motor vehicle use…”, the Organizations contend that in order to “improve” the management of motor vehicle and OHV use, an adequate and varied inventory of routes (i.e., roads and trails) that fulfills the user’s spectrum of needs (today and into the future) for variety, difficulty, destinations, challenge, terrain and scenic opportunity will lead to improved management and compliance. Closure and a reduction of recreational opportunities and the resulting concentration of an ever increasing number of users, has shown again and again that the desired results are not obtained and does not provide a balanced solution to protect the forest resources and does not meet the needs of the recreationalists and other legitimate forest users.
- The Organizations believe it is appropriate and imperative to point out that the current Forest Plan for the PSINF is critically out of date, lacks the framework for current land management and inadequately provides relevant management guidance for the growing needs and demand for multiple-use and motorized recreation, especially OHV recreational opportunities. That the current Forest Plan did not foresee, and therefore does not account for changes in technology such as e- bikes and a escalating growth of UTV/side-by-sides. The Organizations would offer that subsequent planning documents, namely the South Rampart Travel Management Plan (SRTMP) prepared in 2011 more accurately reflects current and ongoing conditions and incorporated relevant and attainable desired conditions in addition to receiving substantial public support from affected user groups. One of the primary purposes of the SRMTP was to determine which motorized roads and trails in the South Rampart planning area were necessary to provide a diverse, functional and sustainable transportation system (similar to the purpose of this action).
- The economic impacts of multiple-use and motorized recreation within the counties and communities encompassed by or adjacent to the PSINF cannot and must not be overlooked. Significant economic benefits are realized by all of Southern Colorado as the public travels to and from their valued destinations within the PSINF. As an example, motorized recreational enthusiasts were responsible for approximately $1.6 billion in direct expenditures relating to motorized recreation in Colorado during the 2014-2015 season1. As popular as motorized recreation is within the PSINF, the economic benefits to local economies and nearby communities must not be undervalued.
- The Organizations support the PSINF’s decision to convert most any existing National Forest System Road (NFSR) to a “trail open to all vehicles” or another trail designation (e.g., trail open to motorcycles, or open to vehicles 50” or less in width).
- Alternative C, as released for public review and comment in the DEIS, has a number of roads that are being considered/planned to be converted to trails, which the Organizations enthusiastically support. However, this alternative also includes 330 additional miles/239 individual road segments that should also be converted to trails. According to the DEIS, the PSI staff reviewed these segments and decided to deviate from their own screening process (Section 2.3.1, page 2-6). The PSI staff must make their decisions based on a science-based process rather than on their own subjective preferences and biases, so the Organizations must insist that this issue be addressed and fixed and that the majority of the 239 segments be included for conversion to trails.
Number of Road Segments to be “Reconsidered” for Conversion to Trails
- The Organizations enthusiastically support the adding of new “Open Areas” (as proposed in Alternative D) as areas open to motor vehicles to Alternative C.
- Seasonal closures that affect only motorized users (e.g. the proposed seasonal closure of NFSR 300, aka Rampart Range Road, Pike Peak RD), are inconsistent with the best available science for protecting habitat2 and seasonal closures must be made universal to all users, both motorized and non-motorized.
In conclusion, the Organizations are pleased to offer our collective assistance and expertise to this extremely important project. We firmly believe that multiple-use access and motorized recreation within the Pike & San Isabel National Forest is, and will continue to be, vitally important to the economic vitality of Southern Colorado and an expected component of the recreational experiences provided by our public lands. We stand behind a sustainable and robust network of multiple-use/motorized routes and trails that sufficiently serve the needs and demands of all forest visitors. Finally, we feel it is obvious but important to acknowledge that as the population along the Colorado Front Range continues to grow, the needs and demands for multiple-use and motorized recreation will only escalate and that it will be imperative that the Pike & San Isabel National Forest works diligently to serve the public by professionally managing and providing the necessary recreational opportunities that support multiple-use and motorized recreation.
We thank you for reviewing and considering these comments and suggestions. The Organizations would welcome a discussion of these opportunities at your convenience. Our point of contact for this project will be William Alspach, P.E. at 675 Pembrook Dr., Woodland Park, CO, cell 719-660-1259, firstname.lastname@example.org.
Scott Jones, esq.
CSA Vice President
D. E. Riggle
Director of Operations
Trails Preservation Alliance
Central Colorado Mountain Riders
Colorado Motorcycle Trail Riders Association
Rampart Ranger Motorcycle Committee
1 DRAFT Economic Contribution of Off-Highway Vehicle Recreation in Colorado, July 2016
2 Sime, Carolyn A; 1999. Domestic Dogs in Wildlife Habitats, Effects of Recreation on Rocky Mountain Wildlife,